03.1.
Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

Carve Capital has a written policy and procedures governing employees' personal account dealing (all personal trading must be approved by Carve Capital in order to avoid potential conflicts). Trading is not allowed in securities or other financial instruments in which Carve Capital, Carve or other Brummer & Partners' companies/funds is executing a transaction, considering executing a transaction or conducting research.

Carve Capital is not allowed to deal in financial instruments with Carve and the same rules for staff and principals also apply for Carve Capital. Carve Capital has internal instructions on how to proceed when investing in funds under its management.

Carve Capital has no relationships with for example associated brokers/dealers that may affect its trading flexibility. Carve retains trading relations with numerous counterparties and seeks to execute trades with counterparties that offer the best services/products compared to price.

Any situation or potential conflict of interest that would or could question our number one priority – to manage Carve as proficiently as possible, is taken very seriously. Therefore, apart from having written policies and procedures, Carve has a sound business culture encompassing professional and sound values for managing money and risk but also business behaviour.